104 Wash. 2d 486 - State v. Hall’s Empirical Analysis
1985
Citation profile
32 state decisions
How this case has been cited
Cited by 32 later decisions — most recently July 2017 · most notably 105 Wash. 2d 175 - State v. Ammons (2005), State v. Sledge (1998)
32 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Santobello v. New York · Spies v. United States · Reed v. Reed · United States v. Murdock · United States v. Bishop
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“state prisoners who escape from work release”. Hall , at 492-93. However, the court resolved the equal protection problem by holding that any time a work release inmate is charged under the escape statute, the State is required to prove that the defendant willfully failed to return to be convicted of first degree escape. By applying this culpability requirement, RCW 9A.76.110 and RCW 72.65.070 will be reconciled and a work release prisoner's right to equal protection of the laws will be safeguarded. Hall , at 493-94. The court in Hall focused on the inequality created between state and nonstate work release inmates due to the different culpability levels in the two statutes. In discussing the two statutes, however, the court did not distinguish between those defendants whose crime is leaving a work release facility without permission, i.e., those who escape, and those whose crime is failing to return. While the culpability elements of the statutes differ, so do the crimes. This distinction is blurred by the court's use of the term "escape”
1 later decision quote this exact passagee.g. State v. Christian“as one convicted of a felony and sentenced to confinement in a state facility, RCW 72.65.070 applies only to state prisoners. Hall , at 492. Since the defendant was not a state inmate, he could only be charged with escape. The court held that his right to equal protection was violated because RCW 9A.76.110, applicable to all prisoners, has a lower culpability element than RCW 72.65-.070, applicable only to”
1 later decision quote this exact passagee.g. State v. Christian“Requirement of Wilfulness[ 1 ] Satisfied by Acting Knowingly. A requirement that an offense be committed wilfully is satisfied if a person acts knowingly with respect to the material elements of the offense, unless a purpose to impose further requirements plainly appears.”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.